05000220/LER-1999-001, :on 990125,noted That Plant Operated Outside Design Basis Due to Failure to Revise Satellite pre-fire Plans.Satellite Copies of pre-fire Plans Were Revised & Procedure Re pre-fire Plans Was Revised.With
| ML20207A847 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/24/1999 |
| From: | Rich Smith, Topley D NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LER-99-001, LER-99-1, NMP1L-1411, NUDOCS 9903050270 | |
| Download: ML20207A847 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ii) |
| 2201999001R00 - NRC Website | |
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NiagarahMohawk' February 24,1999 NMPIL 1411 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Docket No. 50-220 LER 99-01 Gentlemen:
In accordance with 10CFR50.73(a)(2)(ii)(B), we are submitting LER 99-01, "NMP1 Outside Design Basis Due to Failure to Revise Satellite Pre-Fire Plans."
Sincerely, Robert G. Smith Plant Manager - NMP1 RGS/KLL/sc xc:
Mr. H. J. Miller, NRC Regional Administrator Mr. G. K. Hunegs, Senior Resident Inspector Records Management
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j Mr. Dave Topley, Manager Operations NMP1 (315) 349-1752
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At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on January 25,' 1999, with Nine Mile Point Unit 1 (NMP1) in full power operation, an NRC i
Resident Inspector questioned Niagara Mohawk Power Corporation (NMPC) Fire Protection personnel j
concerning commitments that NMPC had made in its November 6,1998, request for exemption from the requirements of 10CFR70.24(a), " Criticality Accident Requirements." When NMPC Operations personnel j ~
reviewed the commitments to answer the resident inspector's inquiry, they determined that the NMPC Fire l
Protection Supervisor had not adequately implemented the commitments made in NMPC's application for i
exemption to 10CFR70.24 (and as granted by the NRC on December 10,1998). Therefore, NMP1 operated outside its design basis from January 12,1999, when new fuel was first placed in the NMP1 new fuel storage
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. vau t, to anuary 25,1999, when the revisions of the satellite Pre-Fire Plans were satisfactorily implemented.
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l The root cause of the event is that the Fire Protection Supervisor failed to implement the required change to the Pre-Fire Plans. While the Fire Protection Supervisor did revise the master copy of the Pre-Fire Plans, the supervisor did not properly implemen;t the change to the satellite copies of the Pre-Fire Plans.
1 Corrective actions included revising the satellite copies of the Pre-Fire Plans, ensuring that all Fire Protection personnel were made aware of the basis for and importance of the change, revising the site services j
administrative procedure for control of Pre Fire Plans, and counseling the Fire Protection Supervisor.
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DESCRH' TION OF EVENT i
i At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on January 25,1999, with Nine Mile Point Unit 1 (NMP1) in full power operation, an NRC e
. Resident Inspector questioned Niagara Mohawk Power Corporation (NMPC) Fire Protection personnel i
i concerning committed actions included in NMPC's November 6,1998, request for exemption from the J
requirements of 10CFR70.24(a), " Criticality Accident Requirements." When NMPC Operations personnel j
reviewed the commitments to answer the resident inspector's inquiry, they determined that although the Fire Protection Supervisor satisfactorily revised the master copy of Fire Protection Instruction N1-FPI-PFP-0101, j
" Unit-1 Pre-Fire Plans," on December 22,1998, the supervisor did not revise the satellite copies of the Pre-Fire Plans. The revision of the Pre-Fire Plans was required to meet one of the commitments made in l
NMPC's application for exemption from the requirements of 10CFR70.24 (and as granted by the NRC's i
letter datai December 10,1998). Therefore., NMPC had not adequately implemented the exemption to 10CFR70.24. NMPC determined that NMP1 operated outside its design basis from January 12,1999, when l
new fuel was first placed in the new fuel storage vault, until January 25,1999, when the revisions of the satellite Pre-Fire Plans were satisfactorily implemented.
On Decemter 10,1998, the NRC i sued " Issuance of Exemption from the Requirements of 10CFR70.24 i
Regarding Criticality Accident Requirements - Nine Mile Point Nuclear Station, Unit No.1 (TAC No.
i MA4130)." The NRC stated that one of the criteria for approval of the exemption (Criterion 3) concerned the k-effective value corresponding to the optimum moderation of fuel. Criterion 3 required that, if optimum J
moderation of fuel in fresh fuel storage racks occurred when the fresh fuel storage racks were not flooded, the k-effective value corresponding to this optimum moderation would not exceed 0.98, at a 95 percent probability,95 percent confidence level. In lieu of performing the optimum moderation analysis, NMPC opted to perform procedure changes that were recommended in General Electric Service Information letter (GE SIL) 152 to reduce the probability of optimum fuel moderation during storage. Consistent with that J
philosophy, NMPC also committed to revising the NMP1 Pre-Fire Plans to further reduce the already low probability ol' establishing critical conditions in the new fuel storage racks. NMPC asserted that those i
controls, along with the design bases for the new fuel storage vault, would effectively preclude optimum i
moderation of fuel in the new fuel storage racks. In its submittal, NMPC indicated that the Pre-Fire Plans j
for the area of the new fuel storage vault were being revised to ensure that, in the event of a fire, firefighting i
foam or water would not be directed toward the new fuel vault during dry storage of new fuel.
On December 10,1998, the Manager Operations accepted responsibility for Nuclear Commitment Tracking l
. System (NCTS) commitment number 504235-00. Nuclear Licensing and NMPI Operations personnel monitored the commitment via Nuclear Interface Procedure NIP-IRG-01, " Interface with the NRC." The
' Manager Operations delegated this task ultimately to the Fire Protection Supervisor who was required to complete the revision to the Pre-Fire Plans on or before December 31,1998. On December 22,1998, the
' Fire Protection Supervisor revised the master copy of the Pre-Fire Plans, and delegated revision of the satellite copy of Pre-Fire Plan located in the Fire Protection office to a Fire Chief. The Fire Chief failed to l
make the revision. In addition, the Fire Protection Supervisor did not realize there were other satellite copies requiring revision in order to satisfy the commitment. The Fire Protection Supervisor then processed the closure of the NCTS commitment believing that the commitment was complete. The Manager Operations approved the closure of NCTS commitment 504235-00, based on these NCTS closure documents.
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DESCRIPTION OF EVENT (Cont'd)
On January 25,1999, NMPC Fire Protection personnel revised the satellite copies of the Pre-Fire Plans, and NMP1 was in compliance with the conditions of the exemption.
II.
CAUSE OF EVENT
l The root cause of the event is that the Fire Protection Supervisor did not exercise an adequate level of thoroughness in implementing the required change, in that he did not revise the satellite copies of the Pre-Fire Plans.
l A contributing factor in this event is that Nine Mile Point Site Services Procedure S-SAD-FFP-0106,
" Preparation and Control of Pre-Fire Plans," did not contain detailed guidance to govern the preparation and updates of Pre-Fire Plans. Per S-SAD-FFP-0106, the Fire Protection Supervisor is responsible for the distribution of the satellite copies of the Pre-Fire Plans. However, procedure S-SAD-FFP-0106 did not list the locations of the satellite copies.
I III.
ANALYSIS OF EVENT
This event is reportable under 10CFR50.73(a)(2)(ii), "Any event or condition that resulted in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded, or that resulted in the nuclear power plant being:... (B) In a condition that was outside the design basis of the plant."
In SECY-97-155, " Staff's Action Regarding Exemptions from 10CFR70.24 for Commercial Nuclear Power Plants," and in NRC Information Notice 97-77, dated October 10,1997, " Exemptions from the Requirements of Section 70.24 of Title 10 of the Code of Federal Regulations," the NRC provided seven criteria for evaluating 10CFR70.24 exemption requests. Criterion 2 states:
I "The k-efiective of the fresh fuel storage racks filled with pure water does not exceed 0.95, i
at a 95 percent probability,95 percent confidence level."
GE SIL 152, recognized that the probability of criticality in a fuel storage vault is extremely remote.
Criticality would require the introduction of a low equivalent water density material (such as firefighting foam) to completely occupy the space in and around an array of fuel assemblies in storage. NMPC's November 6,1998, request for exemption referred to Technical Specification 5.5, " Storage of Unirradiated and Spent Fuel," which stated that the new fuel storage racks were designed to maintain a k-effective of less than 0.95, even with the new fuel storage vault flooded with water. The design of the NMP1 fuel storage vault includes a drain to preclude flooding and an area radiation monitor located within the vault to warn of abnormal radiological conditic,:0
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ANALYSIS OF EVENT (Cont'd)
There is no firefighting foam in the NMP1 reactor building nor on the refuel floor. Fire Protection personnel would use foam for turbine oil fires outside the reactor building, and would employ either dry chemical fire extinguishers or water to extinguish any fire on the refuel floor. Fire Protection personnel would utilize dry chemical extinguishers as the preferred method. Furthermore, the knowledge and proficiency of the Fire Protection personnel was such that they would not have directed water toward the fuel storage vault in the event of a fire in that area, even without the revision of the satellite copies of the Pre-Fire Plans.
Based on the knowledge of the Fire Protection personnel, and the absence of firefighting foam from the refuel floor and reactor building, there was a negligible increase in the already extremely remote probability of a criticality event involving the new fuel storage vault. Therefore, there was no threat to the health and safety of the general public or plant personnel.
IV.
CORRECTIVE ACTIONS
1.
On January 25,1999, NMP1 Operations personnel issued Deviation / Event Report 1-99-0246 to document the deviation and monitor corrective actions.
l 1
2.
The NMPC Fire Protection Supervisor revised all satellite copies of the Pre-Fire Plans on January 25, l
1999, and all Fire Protection personnel were made aware of the basis for and importance of the change.
j 3.
The NMPC Fire Protection Supervisor revised the Nine Mile Point Site Services Administrative Procedure S-SAD-FFP-0106, " Preparation and Control of Pre-Fire Plans," to include further guidance for revision of the Pre-Fire Plans.
4.
The Fire Protection Supervisor was cotmseled concerning the need to apply a rigorous approach to ensuring that regulatory commitments are met.
V.
ADDITIONAL INFORM ATION A.
Failed components: none.
j B.
Previous similar occurrences: none, j
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FACERY NAME (1)
DOCKET NUMBFJL (2)
RER NUMBER (6)
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ADDITIONAL INFORMATION (Cont'd)
C.
Identification of components referred to in this LER:
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- IEEE HO3 FUNCTIONP 2IEEE 805 SYRIEM ID1 New Fuel Storage Vault N/A DB Area Radiation Monitor mon IL
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